While we aim to foster an open and safe environment where people should feel safe to voice concerns and share their thoughts and ask questions, we also realize that is not always possible, and that’s why we want to offer this anonymous reporting channel and whistleblowing service for all Supercellians and our business partners.
Whistleblowing provides an opportunity to report suspicions of misconduct. You do not need proof of your suspicions, but all messages must be made in good faith.
Whilst we ideally would hope you’d feel comfortable raising your concerns and questions to your lead, our legal or People team, you can raise your concern anonymously by using our Reporting channel, managed by a third-party: WhistleB
Here is the link to the reporting channel, allowing anonymous messaging and dialogue: Reporting channel
The Reporting channel can be reached on any device, including smart phones. We recommend you access the channel from a device not connected to Supercell’s network.
Why do we need this channel?
It is the right thing to offer for our employees and business partners.
We need to be compliant with the EU directive on Whistlelblowing (EU2019/1937)
We've also recognized a need for an anonymous channel for our people to reach out to with sensitive matters unrelated to whistleblowing.
How do you ensure anonymous reporting?
By using a third party service, WhistleB, that ensures the anonymity of the whistleblower. The service is separate from our own IT environment. WhistleB does not track IP addresses or other data that could identify a person sending a message. Messages are encrypted and can only be decrypted by designated individuals. WhistleB cannot decrypt and read messages. Please note that if you intend to file anonymously, it is recommended to access the service from outside Supercell’s network.
Who has access to the system?
First line of responders and main users of the system are Markku (General Counsel) and Frida (Co- Chief People Officer). Additionally we have the Legal Team (Hannu and Dave) as well as People from the People Team (Anna, Pat, Jenny and Lauren) who can handle and access cases depending on the matter. Whilst these are the people who access the system, we will of course involve necessary parties in any potential investigations and follow ups.
Who can use this channel?
According to the EU directive all employees and contractors/external business partners should have access to the channel.
What is whistleblowing and why is it important?
Our whistleblowing service offers a possibility to alert the company/organisation about suspicions of misconduct in confidence. It is an important tool for reducing risks and maintaining trust in our operations by enabling us to detect and act on possible misconduct at an early stage.
Whistleblowing can be done by any person openly or anonymously.
When to blow the whistle?
The whistleblowing service can be used to alert us about serious risks affecting individuals, our company/organisation, the society or the environment.
The processing may only refer to data about serious improprieties concerning:
accounting, internal accounting controls, auditing matters, fight against bribery, banking- and financial crime, or other serious improprieties concerning the company’s or the group’s vital interests or the life or health of individual persons, as for instance serious environmental crimes, major deficiencies that regard the security at the place of work and very serious forms of discrimination or harassments.
Employees are asked to contact their lead for issues relating to dissatisfaction in the workplace or related matters, as these issues cannot be investigated in the scope of the whistleblowing.
A person who blows the whistle does not need to have firm evidence for expressing a suspicion. However, deliberate reporting of false or malicious information is forbidden. Abuse of the whistleblowing service is a serious disciplinary offence.
Please note there could be restrictions on the use of a whistleblowing service in certain countries.
How to blow the whistle?
There are different ways to raise a concern:
Option 1: Contact a lead within our organisation.
Option 2: Contact anyone from the legal team by emailing legal@supercell.com
Option 3: Anonymous or confidential messaging through the whistleblower communication channel to the whistleblowing team: Reporting channel
We encourage anybody who shares their suspicions to be open with their identity. All messages received will be handled confidentially. For those wishing to remain anonymous, we offer a channel for anonymous reporting. The whistleblowing channel enabling anonymous messaging is administrated by WhistleB, an external service provider. All messages are encrypted. To ensure the anonymity of the person sending a message, WhistleB deletes all meta data, including IP addresses. The person sending the message also remains anonymous in the subsequent dialogue with responsible receivers of report.
The Whistleblowing Team
Access to messages received through our whistleblowing channel is restricted to appointed individuals with the authority to handle whistleblowing cases. Their actions are logged and handling is confidential. When needed, individuals who can add expertise may be included in the investigation process. These people can access relevant data and are also bound to confidentiality.
If a person raises a concern directly to a lead or by contacting the whistleblowing team in person the message is treated according to these guidelines.
Receiving a message
Upon receiving a message, the whistleblowing team decides whether to accept or decline the message. If the message is accepted, appropriate measures for investigation will be taken, please see Investigation below.
The whistleblowing team may decline to accept a message if:
the alleged conduct is not reportable conduct under these Whistleblowing guidelines
the message has not been made in good faith or is malicious
there is insufficient information to allow for further investigation
the subject of the message has already been solved
If a message includes issues not covered by the scope of these Whistleblowing guidelines, the whistleblowing team should take appropriate actions to get the issue solved.
The whistleblowing team will send appropriate feedback within 3 (or maximum 6 months) upon the date of receiving the report.
Do not include sensitive personal information about anybody mentioned in your message if it is not necessary for describing your concern.
Investigation
All messages are treated seriously and in accordance with these Whistleblowing guidelines.
No one from the whistleblowing team, or anyone taking part in the investigation process, will attempt to identify the whistleblower.
The whistleblowing team can, when needed, submit follow-up questions via the channel for anonymous communication.
A message will not be investigated by anyone who may be involved with or connected to the misgiving.
The whistleblowing team decides if and how a whistleblowing message should be escalated.
Whistleblowing messages are handled confidentially by the parties involved.
Whistleblower protection in the case of non-anonymous whistleblowing
A person expressing genuine suspicion or misgiving according to these guidelines will not be at risk of losing their job or suffering any form sanctions or personal disadvantages as a result. It does not matter if the whistleblower is mistaken, provided that he or she is acting in good faith.
Subject to considerations of the privacy of those against whom allegations have been made, and any other issues of confidentiality, a non-anonymous whistleblower will be kept informed of the outcomes of the investigation into the allegations.
In cases of alleged criminal offences, the whistleblower will be informed that his/her identity may need to be disclosed during judicial proceedings.
Although whistleblowing reports can be made anonymously, they may include data related to named persons or to individuals who are recognizable from the events or circumstances described in the reports. Personal data may also be collected during the investigation of the reports, for example from Supercell employees and IT-systems related to the subject-matter of the report. We only collect data that is needed to ensure an efficient investigation of the reports.
Reports are investigated by a small team consisting of members of Supercell legal and People teams. Other relevant individuals may be involved if necessary. Any personal data included in the reports or revealed during the investigation is kept confidential and used only for the purposes of investigating the suspected misconduct described in the reports and for carrying out possible follow-up procedures aiming at rectifying any misconduct detected.
If you have any questions, reach out to Frida in our People team or Markku in our Legal team, or through the whistleblowing channel available at: Reporting Channel
What kind of data is processed?
Whistleblowing reports contain information on possible breaches of law and of suspected misconduct that is not in line with Supercell’s values and ways of working. The reports may contain personal data such as names, dates when breaches occurred, descriptions of behavior, or other information related to the subject-matter of the report. The types of personal data depend on the subject-matter of the report.
Whose data is processed?
All Supercell’s employees and contractors/external business partners globally can submit whistleblowing reports. Reports can contain data relating to Supercell’s personnel, contractors and business partners.
What is the legal basis of processing?
Processing of personal data in the context of whistleblowing reporting is based on Supercell’s legitimate interest to prevent reputational risk and to ensure that its business is carried out in an ethical and sustainable manner and in compliance with applicable laws and regulations.
How long is the data kept?
Data is kept as long as it is needed for investigating the report and for follow-up procedures. Data will be retained for 2 years from end of the investigation, after which the necessity of retaining it will be assessed.
Is the data disclosed to third parties?
The reporting channel is maintained by our external reporting channel service provider WhistleB, which does not have access to the data in plain text. We may disclose personal data to authorities on a case-by-case basis and in accordance with applicable law, for example if a report leads to a criminal investigation or legal proceedings.
Is the data transferred outside the EU/EEA?
WhistleB does not transfer data outside the EU/EEA.
Data may be transferred outside EU/EEA inside Supercell in case the Whistleblowing team investigating the report includes members located in Supercell offices outside EU/EEA. Such transfers are subject to the same safeguards as other internal data transfers of personal data within Supercell.
What rights do I have?
Data subjects have several rights granted in European data protection legislation. Data subjects have the right to know whether their personal data is being processed, and if that is the case, access to their personal data. The right to access data may be restricted in cases where it would adversely affect the rights and freedoms of others.
Data subjects have the right to have inaccurate data rectified. In certain situations, data subjects may have the right to have their data erased. Data subjects may also have the right to object to the processing of their personal data and to have the processing rectified.
The applicability of all data subjects’ rights is subject to certain criteria defined in data protection legislation. All requests concerning data subjects’ rights will be assessed case-by-case.